Policy SP10: Healthy Communities

This policy is supported especially criterion (a), (b) and (f) as they would be consistent with Government planning policy on creating healthy communities set out in section 8 of the NPPF plus would accord with Sport England's strategy and planning policies.
However, there is considered to be one criterion missing from the policy. The design of new development can play a major role in encouraging healthy and active lifestyles. Sport England and Public Health England have published the Government endorsed 'Active Design' which provides principles, case studies and detailed guidance on how to help create active communities through design which has been referenced in paragraph 9.14 of the plan. Criterion (f) of the policy covers physical and green infrastructure but these only represent a few elements of how development can be designed to encourage active lifestyles.

I agree with the principles of the policies outlined in SP10. I would however strongly recommend incorporating the provision of A4 business facilities into the proposed plans for the new local centres being created. Public houses serve as focal points for the local community. The precedent from recent community developments such as Cambourne, Cambridgeshire suggests that inadequate provision of public houses undermines and slow the establishment of a new community. I therefore object on the basis that the proposals do not currently make allowance for A4 businesses.

The addition of 2500 houses and the accompanying 5000 cars in the Baldock area will increase pollution within the Town. Baldock did have an above national average asthma rate until the bypass removed many lorries from the town centre. Baldock also lies in a natural 'bowl' one that tends to hold any pollution rather than dissipate it. The additional cars will inevitably cause more pollution to the detriment of air quality and peoples health. We know Baldock is susceptible to this, unlike other NH towns & it is also at odds with para 124 of NPPF .

e. Work with Hertfordshire County Council and education providers to ensure the planning system contributes to the provision of sufficient school places and facilitates the provision of new or expanded schools in appropriate and accessible locations.
Then the plan states: Ahead of, or alongside this, some expansion of Knights Templar School may be possible. Equally, it may be necessary to include some secondary provision to the south of the town in the short- to medium-term until the long-term arrangements are finalised and put in place. There is only one, already full, secondary school in the town that CANNOT be used as a stop gap to accommodate any percentage of the high number of people moving to the town whilst proper provision for secondary education is put in place in the long term.

In Paragraph 9.28 of the plan the Council already notes that air quality standards are already close to being exceeded in Whitehorse Street/Hitchin Street. Also we live in Bygrave and chose to live in a village partly due to wanting cleaner air due to suffering from asthma. Not only will we be looking at c.7000 additional vehicles, but a new road being built very close to our houses. This can only further damage the air quality in and around Bygrave.

There are several species of local bird and wildlife eg. the Corn Bunting that will be adversely affected by this wholescale destruction of their habitat and no consideration appears to have been given to this aspect of planning

I would however like to make some further points why the proposals BA2-4 and SP10 are neither effective nor consistent with other policies.
Many people will point to the transport infrastructure because this is something visible to us all. This is demonstrably not up to the standard necessary to support large scale development. But what about all the other key infrastructure and its capacity that needs to be demonstrably deliverable in a timely fashion prior to development such as sewage, water etc to comply with para 177 of the NPPF. Hopefully the inspector will have expertise and look at this rather than relying on representations. Similarly schools, as far as I can see, proper development of Knights Templar School has for years lagged behind the need and numbers enrolled. I do not think the plan meets the effectiveness test.
There are various comments from the planners about things it is planned will be done. But I am afraid I have no confidence that there is anything of substance and credibility behind the words and I am concerned that if the transport assessment required by the NPPF has been produced as required by NHDC/HCC then it lacks credibility. Opportunities to start doing some of the things are already probably lost. The A507 rail bridge had several weeks of work last year but it changed nothing on the footways or actual bridge width and height. If any of the developments go ahead it will make it more difficult to deal with problems in the future. The bridge is a hazard; recently pallets were strewn about following one of the periodic bridge strikes; the risk of hitting pedestrians will increase if the footfall and cycle miles increased. Delays are already caused by bridge strikes and HGVs attempting to turn when they realise at the last minute they cannot get through. Again, this demonstrates the plan is not deliverable and not effective.
Currently the old car repair site opposite "The Engine" pub is being developed for housing. This and the car sale site could surely have been a strategic acquisition to do something about roads and reducing the traffic light chokepoint. And at the same time put in a smallish multi storey car park as found near quite a few stations to do something about car parking for station users which will become a far greater issue if any of the proposed Baldock developments proceed. Presumably the plan is that there will be less rail users given the current proposals to reduce fast services to/from Baldock. Again, this demonstrates the plan is not deliverable and not effective.
Elsewhere, South Road is also heavily used and any more usage (inevitable from BA2,3,4) will be difficult certainly given the increasing parking already going on there. I don't see that being covered. Another specific example where the plan is silent is Clothall Road; this already has vehicles parked nose to tail and it is barely wide enough for a lorry and a car to pass each other. It will only get worse with BA2-4.
I do not know, but do also worry that SP15 (North Letchworth) will also feed more traffic through Baldock. Undoubtedly this happened with the extensive Stotfold developments that have taken place in recent years. And the talk of feeding traffic onto the A1must be more than a little optimistic and not a realistic solution as the A1 is already a problem certainly when traffic gets south of Letchworth. Once again I consider this demonstrates the plan is not deliverable and not effective. It probably isn't consistent with the national policy requiring sustainable developments.
Baldock has seen a considerable volume of redevelopment and increase in the number of houses in the past 20 years due to use of small plots and redevelopment of old commercial sites etc but there has been no visible infrastructure improvement or enhancement and the consequences are far more on street parking adding to general congestion. I do not think it is appropriate to embark on any of the developments BA1-4 until the infrastructure has been addressed. Taken together B1-4 are sizeable and will significantly impact on an already inadequate infrastructure. The plan is not effective.
I could be persuaded that use of current green belt land for SP14 was appropriate if there were good quality substitutions if all the other minus points were dealt with, but the current NHDC plan seems to me to have too much coincidence of needs given that it proposes to use Herts CC land in the main and no doubt they would like to sell at enhanced development values, and it saves them and NHDC looking properly at other more environmentally and green belt friendly areas. As it stands, I do not see the plan as compatible with para 80 of the National policy framework nor with the NHDC green belt review and think that BA2-4 and SP14 would be examples of undesirable urban sprawl. It is therefore not consistent with the national policy on sustainable development.
Taking the likely increase in stationary traffic, health problems associated with pollution must surely increase and make the policy on healthy communities infeasible.

As I am sure you are aware the North Herts local plan has caused a great deal of concern amongst local residents and I wanted to include my representations for consideration even though I am sure these mirror those of a great number of local residents. I believe the plan as it currently stands does not comply with the National Planning Policy Framework. Whilst most people could accept some degree of development, proposals which increase the town population by 80% and increase the number of cars by as many as 5000 will destroy the town heritage and overwhelm the infrastructure

Specifically I believe these to be the main issues
1. NPPF Section 4 - promoting sustainable transport.
1. Currently the crossroads in Baldock town centre, linking Whitehorse Street to the High Street is a significant bottle neck. The plan currently has 2800 homes planned for north of Baldock. As things currently stand, a trip across Baldock in morning rush hour, starting in Bygrave takes as much as 45 minutes, with traffic streaming back towards the A1.
2. The significant number of new residents will likely be rail commuters. There appear to be no plans to accommodate extra parking at Baldock station and the rail company, Govia are currently in consultation to downgrade the Baldock service. As things stand many trains into and out of London from Baldock suffer from significant overcrowding. I have doubts as to whether the current rail service and station at Baldock could cope with the addition of additional commuters from more than 3000 new homes in the town
3. In the absence of accessible town centre parking to accommodate more cars, the additional strain on parking capacity will effectively isolate residents from both upper and lower Bygrave, who, unable to walk into town will have nowhere to park should they drive


2. NPPF Section 9 - Protecting green belt land
1. The individuality of the town will be lost by this upsurge in population. In addition the area on which the houses are planned is very scenic. There are alternative brown belt sites in the area which could be used to absorb at least some of the proposed development.
2. Bygrave is a rural community and a scenic, historical village. This identity will be lost with the number of houses proposed at the North Herts site and effectively create 3 pockets of housing


3. NPPF Section 2 - Ensuring the vitality of town centres
1. I have not seen any plans for additional parking in Baldock town centre. Even though it is only a 15 minute walk into the town from the north Baldock site, we know many people take the car even for short journeys. This will strangle the town.


4. NPPF Section 17 - Promoting healthy communities
1. I have not seen robust plans for schooling to accommodate such a drastic uplift in population. This is key. The schools in Baldock are already extremely difficult to gain entry into (the acceptance criteria to Hertsfield Primary school in 2015 was 360 metres distance to the school gates). Knights Templar secondary school is excellent, but is also heavily over-subscribed. Without adequate planning for schools existing resident's children in the rural communities such as Bygrave and Ashwell face horrific commutes. Going out in the direction of the Cambridgeshire villages then having to come back through Baldock
2. The road planned to link Bygrave Road with the A507 roundabout is planned to be above ground. This will create a great deal of noise and destroy the beautiful views. I believe if this road is to be built it should be in a cutting and go under the railway line.

I understand the need for additional development in Baldock, however I strongly believe the scale of planning is disproportionate with what can be coped with by the town. 3,290 homes are simply too many and I do not believe the local plan complies with the NPPF in several areas.

As a professional I understand the need for the provision of new homes and the need for a new Local Plan setting out where these homes will be delivered across the district.

My concern as a resident in the district (I live in Royston) is that the provision of facilities including health care, dentistry and leisure facilities are insufficient to meet the demands of the increased number of residents.

Being a recent Immigrant from Africa ( 12years) and used to wide open spaces I find the proposed Developments in our area ,to say the least ,extremely alarming. I shudder to think of how the Infrastructure like Schools, Hospitals, Policing, Surgeries and above all Roads are going to cope? I find it a Nightmare driving on Country lanes and some A & B Roads due to the extremely poor condition..on some of our local roads potholes have been there for past 18 months, even though they have been reported!
The damage to car suspensions must be costing a fortune to repair ..I know from personal experience and cost.

So my main concerns are 1. Medical and 2 Roads and Traffic congestion.

Policy Sp1 - Sustainable Development in North Herts Building 300 plus houses onto a village of 340 properties is not meeting in a sustainable way the needs of the residents of Wymondley. It brings with it issues of coalescence.
There does not appear to be in place any infrastructure, support plans or funding which would be needed to support a development of this scale.
The council has produced no evidence of exceptional circumstance to build on the Green Belt. They have unused Brownfield sites and non- Greenbelt sites available.
A development of this scale with hard surface run-off, particularly from roadways, will increase the flood risk in Little Wymondley which has a recent history of significant flooding.

Policy Sp 5 - Countryside and Green Belt This supports the principles of the Green Belt. The council has not, we believe, demonstrated or justified removing land from the Green Belt to make it available for building.

Policy Sp 6 - Sustainable Transport
The local area is already prone to gridlock on a daily basis in the rush hour and any minor delay can be the trigger.
The junction in Great Wymondley is identified by the council themselves as a particular problem. It already it has extremely high levels of 'rat running' as the Neighbourhood Plan traffic data confirms.
The local country lanes cannot simply be widened as this would destroy the rural nature of the parish.
The situation is made worse by the inability of the A1M to cope with the volume of traffic, forcing motorists to use alternative routes through the villages.

Policy Sp 8 - Housing
A 100% increase in the size of Little Wymondley housing stock is disproportionate to local needs as confirmed by the Neighbourhood Plan.
Hitchin on the other hand is just being asked to have a 10% increase!

Policy Sp 10 - Healthy Communities
Removing existing Green Belt land seems to be at odds with the policy statement to protect, enhance and create new physical green infrastructure to foster healthy lifestyles.
The levels of airborne pollution on the A602 already regularly exceeds the legal limits at the Air Quality Monitoring Point and is already one of the worst in the county. Additional traffic can only make the situation for the residents.

Policy Sp 11 - Natural Resources and Sustainability There is no budget to address the issue of the collapsed culvert in Stevenage Road which contributes significantly to flooding risk.
The drain clearing programme is ineffective and also adds to the flooding problem.
The SuDs regulation would not cover all aspects of a potential large scale development and hard surface run off would again contribute to potential flooding. The EA flood maps also shows the potential for water run off from the south of Stevenage Road.

Site WY1

The surface water movement through Little Wymondley is a major issue and there is currently no structural plan or adequate financial commitment to address this issue satisfactorily .
Currently surface water runoff from agricultural land to the north of the village and downstream water from Corey's Mill is sufficient to create flooding of properties in Stevenage Road Little Wymondley as has happened historically.
There is not just the problem of surface water runoff from the possible additional building in Little Wymondley but the construction of hundreds of houses in the upstream catchment area on the eastern side of the A1M with its associated runoff.
Additionally plans by Stevenage Borough Council to build an industrial complex directly on the flood plain at Corey's Mill will make the situation even worse.
Downstream at Nine Springs at the bottom of the Wymondley Road a greater flow of water will create a significant additional flood risk to properties bordering the stream culvert.
A practical and funded solution must be found for these problems before any commitment to further building is given the go ahead.

In Conclusion:-
The Wymondley Neighbourhood Plan states the residents' acceptance for housing need but that it must be on a manageable scale.
The Plan also clearly states opposition to building on Green Belt land which provides space between the area's villages and towns thus preventing urban sprawl eliminating the rural nature of a North Hertfordshire.
Clearly the traffic and flooding issues of the area need to be resolved before consideration is given to any substantial house building.
A retrospective approach with the traffic gridlocked and flooded properties in the area is not the way forward.

See attachment

See attached

I wish to object to the Local Plan as I consider it NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY.

Policies SP8 and SP14 - The proposed allocation of 2,800 homes at North of Baldock (site BA1).
Other policies referred to are SP1, SP4, SP5, SP6, SP7, 9, 10, 11, 12, 13.

1. This site is acknowledged by the council as making a significant contribution to Green Belt purposes (Housing and Green Belt background paper para 3.14.
The Plan is UNJUSTIFIED as it is not the most appropriate strategy.

2. Table 4 sustainability appraisal notes that this site creates a high probability of adverse impacts on landscape and townscape character and Landscape Sensitivity Study of July 2013 identifies the land north of Bygrave as having moderate to high landscape sensitivity. The Bygrave Road from Baldock has environmentally protected grass verges.
The Plan is UNJUSTIFIED as it is not the most appropriate strategy.

3. Baldock sits in a valley which is well known for having poor air circulation causing air pollutants like PM2.5 from diesel emissions to be trapped and concentrated. The Eastern Baldock Bypass was finally built in 2003, following intervention in parliament by Sir Oliver Heald MP, to alleviate this pollution. Before the build asthma levels in 5-16 year olds was at 15% and the bypass brought them down to the national average of 6%.
Since then traffic has risen and now the levels of pollutants in Hitchin St and Whitehorse St are in danger of exceeding EU permitted levels (para 9.28). The Housing and Green Belt background paper notes that former site 209E (Priory Fields Hitchin) was considered unsuitable for exactly this reason.
The extra vehicles, domestic and service vehicles, which will arise from the building of 3,590 new homes and which will travel through and around Baldock will tip the balance and affect the health of all residents especially the very young, the old, pedestrians and cyclists raising health problems such as respiratory disease, cardiac problems and even cancer.
The Plan is UNJUSTIFIED as it is not the most appropriate strategy.

4. The local highways network will be severely affected by the development of this site.
Almost all of the traffic wishing to pass through Baldock travels from the A1 to Buntingford and Stanstead along the A507, and from Cambridge and Royston towards London along the A505 (now redesignated B656), and these two roads cross at traffic lights at the north of Baldock at Station Road and Whitehorse Street. The two roads are offset and the traffic lights are slow because of three way lights and now pedestrian crossing time when requested, mainly at school rush hours. The crossroad is bounded by listed buildings which makes turning difficult especially for the huge lorries on the A507, some going left to Royston at that junction, which still go that way despite recommendations that they use the A1 and new bypass. One of the listed buildings has suffered many hits by vehicles.

The proposed mini-roundabout at Whitehorse St/Station Rd crossroads, the only mitigation planned for Baldock (AECOM technical note para 5.1, Draft report of North Herts Local Plan Model Testing Table 5.1) may reduce accidents between vehicles but will not reduce time spent and congestion caused by this junction.

The A507 passes the only access road to the railway station causing extra congestion in peak travel periods. The railway access is shared by about 100 houses in a cul-de-sac, Icknield Way East, and work is currently in progress to build another 41 houses which will also have to use this access. The survey used to discuss traffic impact of these new houses at this junction refers only to Icknield Way East, not the Station Approach nor the A507 on to which they both deliver traffic. Inadequate research and modelling.

Station Road passes under the 14ft 6in railway bridge which historically has suffered frequent hits by lorries (8 or so per year). Despite the building of sacrificial metal beams at each side of the bridge and new signage the hits continue to occur. Whilst the long delay to rail traffic no longer happens, road traffic is still impacted while the mess is cleared up, the vehicle is extracted, two police vehicles are deployed. In addition to this there are numerous smaller holdups when lorries realise they will hit the bridge and manoeuvre via small residential roads damaging road furniture and grass verges as they do. See appended photo of lorry hitting bridge just before photo taken at 12.43pm on November 9th 2016 necessitating two police vehicles. Also the screen shot of ongoing congestion as a result at 1.30pm. This is a regular occurrence. Screenshots of the A507/ B656 junction and A1 at other random times show congestion.

The traffic on the A507 is constant and heavy especially in peak periods which extend over at least two hours and are worst in school term time. It also increases any time of day or night if there is a crisis on the A1. The A507 is not shown as a "key feature to transport in North Herts" IDP (para 5.4) despite being now arguably the busiest road through the town. A survey of all Baldock roads at the time of the Bypass inquiry showed that this would be the case.

In the IDP the Traffic Baseline (para 5.1) shows that for North Herts as a whole traffic volume between 2014 - 31 is expected to increase by 16.1% and the average commuting distance in 2011 was 19.4km. Rail patronage at Baldock (para 5.12) went up 61% between 2005/6 to 2014/15. Para 5.19 mentions cycle paths in North Herts including Baldock but those referred to are mainly for leisure. Traffic demand in the A1 corridor may increase by 30% by 2031.

No traffic surveys on the A507 have been carried out by NHDC for development of this Local Plan. It has not been included in any meaningful traffic modelling exercises during research and forward planning. I can report, as a resident of this road, that the traffic volume has increased substantially since the Bypass was opened in 2003 and particularly since the A1 services at Radwell were built. GPS navigation also directs traffic along this road as an alternative to the A1/ Eastern bypass.

All of this ensures that the A507 from the traffic lights to the A1 roundabout is not a suitable road to give access to a new development at BA1 as NHDC plans. It is very likely, since there are few work opportunities in Baldock, that most of the residents will commute to other parts of North Herts, Bedfordshire and Cambridgeshire. NHDC has projected 2-3 vehicles per house so 5-7000 vehicles at least can be expected to be generated from this BA1 site and most will want to visit Baldock, Letchworth, Hitchin i.e pass through the traffic lights at Station Rd /Whitehorse St.

The link roads proposed by NHDC will do nothing to solve this traffic problem. A "northern" link is proposed through the BA1 site and a "southern" link road is mentioned between BA 3 and BA4 but with even less substance. No information is provided as to route impact or viability. Indeed these roads threaten to conduct traffic of all descriptions through the new residential areas forming a real hazard to residents both by potential accidents and by air pollution. These roads are referred to in the Infrastructure Delivery Plan para 5.110 and it is stated they "have been included in the traffic modeling." But where is the evidence? Their "provision (cost and delivery) is assumed to be absorbed within the specific proposals for these areas and they are subsequently not specifically identified in this IDP." This and the fact that Baldock is listed as a separate town but in traffic terms is always grouped with Letchworth which has its own completely different transport problems is concerning, leading to the belief
that Baldock traffic problems have not been acknowledged and addressed. There is no Masterplan for BA1.

The Plan is UNJUSTIFIED and NOT EFFECTIVE. There is insufficient evidence that the development can be achieved without a huge negative impact on the local highway network. This applies also in respect of BA4 and BA10 (SP8 and SP14).
There is no adequate Transport Assessment or Transport Statement and the Plan is therefore NOT CONSISTENT WITH NATIONAL POLICY.

5. Baldock's railway station is on the northern edge of the town with few houses lying to the north of the railway line. A major development on this side of the railway line would result in a pinchpoint for traffic at the WhiteHorse St/ Station Road intersection. The AECOM's technical note, table 4.1, identifies this crossroad and Letchworth Gate at the southern end of Baldock as problems (above capacity, unacceptable queuing) by 2013 even without further development.

The Plan acknowledges that "not all" traffic from BA1 will have to use the Whitehorse St/Station Rd crossroads (4.179) but this also acknowledges that a good proportion of it will. The Plan makes employment provision at above modelled levels SP3, 4.26 and this could increase traffic flow between Baldock and Letchworth and Hitchin. The plan stresses how interconnected Baldock, Letchworth and Hitchin are (paras 2.31, 4.27, 13.14) and that many residents commute out (4.25, 4.26). This will lead to more peak hour traffic.

Since it is expected that most new Baldock residents will commute to work outside Baldock, as well as extra pressure on the roads there will be unacceptable pressure on the railway. The station is small and would need extending to accommodate more passengers and the longer trains needed for them. Govia are currently holding their own consultation on their future rail provision and intend to cut "fast" trains stopping at Baldock other than at peak rush hours. This will not serve 7-8000 extra people well. Moreover British Rail had not till recently known of the Local Plan which includes recommendations such as building a bridge over the railway from the A505 Royston road into or round the BA1 site.
There is no information on deliverability or cost of this proposed road / railway crossing which will be very expensive if it is to be delivered without visual impacts as it is quite exposed at this point.

This indicates that NHDC has produced a poor plan without much forward planning and appreciation of all the related infrastructure required.

The link road proposed through BA1 will not relieve congestion at the Whitehorse St/ Station Rd crossroad if it is not the shortest route into Baldock. It may, however, be used by many people as a shortcut from A505/ B656 to A507 and will deliver more air pollution to the site BA1. Roundabouts through this development would increase air pollution and associated problems as brakes and gearboxes add to particulate production.

There is no modeling of the impacts from Baldock developments BA1-4 and BA10 employment area or their dependency on new infrastructure (AECOM section 7 Summary). No information is given about mitigating measures. It has not been shown that this part of the plan is deliverable.

The Local Plan Viability Assessment (update 2016) has not considered specific infrastructure pressures and mitigation concerns associated with the major sites, of which BA1 is the biggest proposed.

The Plan is NOT EFFECTIVE as it cannot be achieved without considerable negative effect on transport and local highway network.

6. The National Planning Policy Framework states in para 32 that "All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. Plans and decisions should take account of whether.....the opportunities for sustainable transport modes have been taken up" but the Plan does not give information of things such as cycleways between towns for commuters, "safe and suitable access can be achieved for all people" but the increased traffic on A507 and through any link road and under the very narrow railway bridge will act against this, "improvements can be taken within the transport network that cost effectively limit the significant impacts of the development. Development should only be prevented or refused where THE RESIDUAL CUMULATIVE IMPACTS OF DEVELOPMENT ARE SEVERE". I believe that in this case they are severe.

The full impact of the scale of development proposed for Baldock - 3590 homes BA 1/2/3/4 and BA10, industrial development, or the individual major sites,- have not been properly assessed. Nor has evidence been offered on the impact of these developments on the existing town of Baldock and its environs and its local transport network. No information has been given about proposed mitigation measures.

The Plan is NOT CONSISTENT WITH NATIONAL POLICY.

7. The Plan does not retain and enhance the town centre of Baldock as recommended by the NPPF (para 23). Indeed by trying to build a new development BA1 on the other side of the railway line it encourages a pinchpoint for traffic and a pulling apart of the community.

Developments should "be expected to work closely with those directly affected by the proposals to evolve designs that take account the views of the community" (NPPF 66) but NHDC have not done this. They have not sought the views of existing residents.

"By designating Local Green Space local communities will be able to rule out new development other than in very special circumstances". But NHDC have decided to locate many sites including BA1 on Green Belt land, going in the face of this policy. They have not provided appropriate justification for redesignating Green Belt land as they should, showing "exceptional circumstances". Indeed the area BA1 is acknowledged by the Council as making a significant contribution to Green Belt purposes as shown in NPPF chapter 9. It is good quality agricultural land and of great importance for feeding the local area. "Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use poorer areas of land in preference to that of a higher quality" NPPF 112.

Water provision, at a time when water in this area is scarce and in danger of being inadequate, and the provision of sewerage over an enormous area (BA1) have not been adequately documented. The protection of the Ivel Nature reserve has been glossed over as has the mitigation measures for protection of other wildlife such as the endangered corn bunting on BA1.

"It is important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion" NPPF 177. The Council have failed to provide detailed plans, timescales or costings for the necessary infrastructure and this gives no confidence that said infrastructure will be provided at the times it is needed, of a good quality, or even at all. Other developments in the area e.g. Great Ashby have discovered this to their cost.

The Plan is neither JUSTIFIED nor EFFECTIVE nor CONSISTENT WITH NATIONAL POLICY.

If indeed development on this scale is really needed in North Herts then I support Sir Oliver Heald in his recommendation to build a new settlement instead of tacking on large areas of development such as these in Baldock which create real problems for the future of existing communities whilst destroying their heritage.

I should like to be kept updated on the Plan's progress
I should like to be invited to the Public Hearing.

Section 1:

Knebworth Estates congratulates North Hertfordshire District Council on a Plan that has - not before time - been positively prepared, and - within its delayed and limited time frame - appears justified, effective and consistent with national policy.

Section 4.9 - Policy SP2:

Knebworth Estates supports Knebworth's inclusion as a Category A village, and Old Knebworth's inclusion as a Category B village - although it argues that there are sometimes cases where it is preferable for a village to evolve outside of its "built environment" rather than on the open and green spaces within its "built environment", and that the Plan should allow for such cases.

Section 4.37 - Policy SP4:

Knebworth Estates supports the Plan's commitment to protecting the vitality and viability of the range of retail facilities in the local centre of Knebworth.

Section 4.127:

Knebworth Estates supports the Plan's commitment to deliver appropriate primary and secondary school facilities for Knebworth.

Section 4.162:

Knebworth Estates supports the Plan's commitment "to find new, appropriate uses and solutions to secure the future of heritage assets."

Section 4.165:

Knebworth Estates does not support the Plan considering serving Tree Preservation Orders within historic parks and gardens as this could run contrary to the Plan's commitments in Section 4.162 and the management of historic parks and gardens - and the preservation of, interpretation of, and access to, the heritage assets within - are unlikely to be any better served than by those to whom it is a day-in-day-out commitment and responsibility. Knebworth Park and Gardens has its own Historic England approved Conservation Plan and an exemplary record in its heritage management, and yet another level of statutory requirement is unjustified, unnecessary and counter-productive.

Section 5.28 & 5.29:

Knebworth Estates supports the Plan's intent that Knebworth village centre should continue to provide a mix of shopping, services and community facilities.

Sections 5.39 to 5.48 and Policy ETC8:

Knebworth Estates supports the Plan's commitment to Tourism and argues that - whilst being an Historic England "Priority Building At Risk" - Knebworth House and Knebworth Park belie Section 5.41's statement that North Hertfordshire is not a major tourist destination. The Visit Herts DMO, VisitEngland, the LEP, and Hertfordshire County Council all recognise the district's strong tourism draw and impact. Knebworth House is one of only two Historic Houses in Hertfordshire with a national profile (the other being Hatfield House in the Welwyn and Hatfield district) and Knebworth Park is unique nationally in its capacity for large music events. The Plan should be aspirational to the benefits and potential of Tourism.

Section 6:

Knebworth Estates broadly supports the Plan's Green Belt policies - although, as in Section 4.9, Policy SP2 above - it argues that there are sometimes cases where it is preferable for communities to evolve outside of the "built environment" rather than threatening the quality of life, open and green spaces, balanced zoning and heritage of the "built environment". Knebworth Estates supports the consideration of "exceptional circumstances" within Green Belt policy.

Section 12 - Policy HE2:

Knebworth Estates supports the Plan's "Heritage at risk" policy.

Section 13.183 to 13.202 - Knebworth:

Knebworth Estates supports the Plan's policy for Knebworth within the context and scope of the Plan's objectives and time scales.

Ref - Knebworth - KB1 & KB2:

Knebworth Estates supports the Plan's Housing Allocation and site specific criteria for KB1 and KB2:

Commitment

As freehold owners of the sites identified as KB1 and KB2, Knebworth Estates reiterates its commitment, as expressed in previous consultation responses - and in consultation responses of the independent charity representing Knebworth House (The Knebworth House Education and Preservation Trust), to which Knebworth Estates is primary donor - that if these sites are brought forward for residential designation, it will move swiftly to work with the Council to deliver the full required housing targets with maximum sensitivity to the community of which it has been a part for over 500 years.

Proof of this commitment is to be found in the Estate's long record of involvement in the evolution of the community of Knebworth - since the settlement's beginnings - and specifically, in its multi-generational quest to restore and protect Knebworth House, its Park and curtilage, for public benefit and access (see "Opportunity" below).

The Estate treasures Knebworth's green spaces and environment - it has been a long term guardian of these - however it also believes that Knebworth should play its part in contributing to housing need identified in the Plan, and in the planned evolution of the District as conceived in the Plan. It recognises, with the Plan, Knebworth's pre-existing infrastructure - "a good range of facilities including a railway station, school, doctors and dentists, library, a range of shops, village hall and churches" - and thus considers it right that Knebworth shares responsibility to provide for residential growth with other communities in the District.

As part of Local Plan residential growth, the Estate supports the provision of affordable housing and schemes to provide homes for those who have grown up in the community. It recognises that new homes generate extra pressure on schools and supports increasing school provision. Increased school provision will strengthen Knebworth's independence of Stevenage and other growing towns, promote community spirit - a deficiency identified in the Knebworth Parish Plan (April 2007) - and ease pressure on road and rail networks at peak times.

Delivery

The Estate recognises the extensive evidence base compiled by the Council to support the suitability of sites KB1 and KB2 and looks forward to working with the Council, the community, neighbouring landowners and future development partners to conduct further studies to confirm and expand on this evidence, which it believes to be sound.

The Estate is pleased to have already contributed to existing evidence with input into Knebworth Parish Council's Knebworth Parish Plan (April 2007 - http://www.knebworthparishcouncil.gov.uk/uploads/knebworth-parishplan-1sted-web.pdf) and Knebworth Sites Appraisal Report (December 2007 - http://www.knebworthoptionsreport.org/).

Sustainability

The Estate recognises the Council's Capacity and Sensitivity Studies of 2006, and - as part of the community, and its owners resident within the community - is particularly sensitive to the issues raised by those who oppose development on these sites. It has listened to, recorded, and considered the practical concerns of its neighbours - through previous consultations, involvement in the Knebworth Parish Plan (April 2007) and the Village Appraisals of 1996 and 2007, and at a number of public meetings over the years - and is confident there are practical solutions and mitigations to the issues raised.

The Estate would seek - in working with the Council, any development partners and its neighbouring landowners - to work with Knebworth's new Neighbourhood Plan to promote a balance of achieving the Local Plan's targets, addressing sustainability and infrastructure issues and concerns, and fulfilling community aspirations. Within the parameters of the Plan, it would look to development in keeping with - and improving on - Knebworth's existing Conservation Areas and Edwin Lutyens' original 1910 framework for "Knebworth Garden Village".

Opportunity

Reinforcing the Estate's commitment, and adding to the opportunity of facility and infrastructure improvement in the wider community, is one factor that is unique to Knebworth Estates. Reflecting the intent of the Plan in Policy SP13a - "Maintaining a strong presumption in favour of the retention, preservation and enhancement of heritage assets and their setting" - the Local Plan's requirement of Estate sites for residential provision would present a once-in-a-generation opportunity to solve the Estate's multi-generational quest to endow the Knebworth House Education and Preservation Trust, a charity created in 1984 for the preservation and enhancement of the heritage asset of Knebworth House and its setting.

Residential designation of KB1 and KB2 would result in sufficient funding for this charity to halt the decay of Knebworth House - an Historic England designated "Priority Building At Risk" - complete its half-finished programme of urgent restoration, and secure an endowment for its future survival, and continued and expanded public access and interpretation.

The Knebworth House charity's record over its 33 year history, its established "exceptional circumstances", its Conservation Plan as submitted to North Hertfordshire District Council in July 2001 - and the Estate's record in endowing, and seeking to complete that endowment - is evidence of the commitment of the Estate and the Charity.

The collateral opportunity presented by the designation of KB1 and KB2 within the Local Plan therefore extends beyond the crucial issue of local residential shortfall, to address also major issues of benefit to the whole region and the nation beyond.

Ref - Knebworth - KB4:

Knebworth Estates supports the Plan's Housing Allocation for KB4. Whilst comfortable that KB1 and KB2 could be successfully delivered without KB4, Knebworth Estates expresses its support for KB4. The Estate enjoys a close and mutually supportive relationship with the landowners of KB4 and, in the event that both landowners have sites proposed for development in the final Plan, we would look to work closely with each other to take an holistic view of Knebworth village and, together, maximise infrastructure advantages for the greater benefit of the wider village and its long-term future.

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TO THE LOCAL PLAN 2011-2031 BY NORTH HERTFORDSHIRE DISTRICT COUNCIL (NHDC)

(I want to change the Local Plan and I wish to participate at the oral examination)

1. I JUDGE THIS PLAN TO BE UNSOUND

The plan is unsound for the following reasons:

1) The Plan is not Positively Prepared
2) The Plan is not Justified
3) The Plan is not Effective
4) The Plan is not consistent with National Policy

NOT POSITIVELY PREPARED

Plan Policy SP8

Para 158 of the National Planning Policy Framework (NPPF)

1.00 Reliance upon figures, estimates or instructions obtained from the Dept. of Communities and Local Government (CLG) or the Office of National Statistics (ONS) does not remove the obligation of the Local Plan from complying with Para 158 when assessing housing need. The NPPF gives the guidance that the CLG Projections are the appropriate starting point in determining objectively assessed need but the CLG projections are only appropriate when they are in accordance with Para 158.

1.01 It should be noted that Para 158 refers to the economic, social and environmental characteristics and prospects of the area of the local planning authority except for that allowed by Para 182.

1.02 There is considerable reason to doubt the adequacy, up to date-ness and relevancy of the CLG household Projections and whether they provide a full account of relevant and economic signals as required by para 158.

1.03 The CLG household projections call for an increase of 15000 houses for North Herts between 2011 and 2031. This is an annual rate of increase of 1.39 %. These figures are employed as the basis for the Objectively Assessed Housing Need for the Local Plan.

1.04 The CLG household projections are, according to the CLG, based upon the 2014 ONS sub-national population projections for the East of England. These figures are calculated for the period 2014-2024. The population increase over this period is given as 8.9% or 0.89% per annum. Thus the CLG, in their household projections, give a rate of population increase 56% larger than the ONS figures. There is not the adequacy, up to date-ness or relevancy (as required by para 158) in the CLG figures to explain why they ae that much larger than the ONS figures.

1.05 Should some of this 56% increase in households by the CLG figures be to satisfy the unmet housing requirement of a non-neighbouring area, such as London, then in that case the Plan contravenes para 182 of the NPPF which states:- The Plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so.......

1.06 The ONS 2014-2024 sub-national population figures for the East of England do not themselves take into account the effect of an imminent Brexit event. Robert Goodwill, The Minister of State for Immigration has stated in November 2016 that the government is committed to reducing net immigration to sustainable levels - which he defines as "tens of thousands". This is a considerable reduction on pre-Brexit projections. It would imply a maximum net migration of 90,000. i.e.0.14% per annum (total pop.64.6 million). Brexit is expected to occur some time after March 2017. with some 14 years of the Local Plan yet to follow. Thus a Brexit event is very relevant and should be taken into account under the requirements of Para 158.

1.07 This post Brexit expected lower level of migration decreases the ONS 2014-2024 total annual sub-national population increase for the East of England to 0.46% from the pre-Brexit figure of 0.89%. Thus the reliance on 2014 ONS pre-Brexit population projections by the CLG and therefore also by the Local Plan, does not give the adequacy, up to date-ness and relevancy as required by Para 158.

1.08 It should be noted that the pre-Brexit 2014 sub-national population figures for the Est of England include an annual increase of 0.28% for internal UK migration. If this internal migration is to satisfy the unmet housing requirement of an non-neighbouring area, such as London, then the Plan contravenes Para 182 of the NPPF which states:- The Plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so.....

As London grows at a fast rate it is most likely that this is the source of the internal migration into North Herts. By not stating from where this internal migration originates the ONS subnational projections are not adequate for use by the Plan as required by Para 158.

1.09 The Plan calls for an increase in houses of 16900 over 20 years on a starting stock of 55150, which is an average annual increase of 1.53%. This, in turn, is an increase which, once again, does not meet the adequacy , up to date-ness and relevancy required by Para 158.

1.10 The proposed rate of average annual rate of increase of housing stock employed by the Plan of 1.53% should be compared with the post-Brexit adjusted 2014 ONS sub-national population projections for the East of England of 0.46% (internal migration not included). The difference amounts to 11830 houses - much of which is allocated to be built on Green Belt land. Legitimate internal migration would require some of these.

1.11 The Plan, in proposing so many more houses than are needed for local requirements, acts to encourage migration into North Herts by creating a availability of houses beyond local needs. This effect is the opposite to the requirement of Para 158 which states that the Local Plan should be based on up to date and relevant evidence about the economic, social and environmental characteristics and prospects of the area.

Whether potential migrants exist in other areas capable of being attracted to the NHDC area is no concern of the Local Plan, except where there is unmet need from a neighbouring area. The unmet need from both the Luton and Stevenage areas has not been properly quantified according to the requirements of Para 158 for the same reasons as given above for the NHDC Local Plan.

1.12 A further relevant factor ignored by the Plan contrary to Para 158 is the inability, or lack of desire, of developers to build beyond a certain rate. Ths effect has been pointed out by the CPRE in their paper "Set Up To Fail". On average developers build just 50% (taken over the last 15 years) of what there is land available for. In this respect the Plan does not comply with Para 154 of the NPPF which requires plans to be realistic.

An unfortunate consequence of making too much land available is that developers are given a choice of which site to develop and they usually choose a Green Belt site in preference to a Brownfield site as it is cheaper for them to build on.

NOT JUSTIFIED

2.00 The Plan is not the most appropriate strategy as it proposes to build many more houses than are required on the evidence supplied or are likely to be built (see under Not Positively Prepared). Furthermore it breaches the NPPF both in the Foreward, Core Planning Principles and Paragraphs 14, 15, 17, 79, 80, 83, 89, 158 and 182 (see under Not Consistent with National Policy).

NOT EFFECTIVE

Plan Policy SP8

3.00 The Plan is not effective as it ignores the rate at which developers ish to build houses. This effect is described in the CPRE Paper "Set Up to Fail". On average developers build just 50% of what they have land available for. This gives the developers a choice of which site to develop and they usually choose a Green Belt site in preference to a Brownfield site as it is cheaper for them to do so. Thus the expected build rate of developers is a relevant factor in any Local Plan.

The Plan is also not effective as it proposes to build many more houses (16900 in total) than is required (see under Not Positively Prepared above).

NOT CONSISTENT WITH NATIONAL POLICY as outlined in the National Planning Policy Framework (NPPF)

The paragraphs listed below refer to the NPPF unless specified otherwise:

4.00 The Plan contravenes the NPPF in sites BA1, LG1, NS1,HT1, GA1,GA2.EL1, EL2, AND EL3 for the reasons given below:

4.01 The Plan contravenes the 1st Core Principle of Para 14 of the NPPF notwithstanding the statement of community involvement, Para 1.19 of the Plan.

The Ministerial Foreward of the NPPF notes that in recent years planning has tended to exclude, rather than include, people and communities and the NPPF allows people and communities back into planning.

4.02 This is addressed by the 1st Principle in Para 14 which states: Planning should empower people to shape their surroundings

and also by Para 155 which states:- Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be pro-actively engaged

4.03 The great majority of representations to the earlier stage of consultation (2014) of the Local Plan (7502 objections versus just 559 supports) have been ignored. Despite the many objections against building on Green Belt land, the amount of Green Belt land allocated for housing was actually increased after the consultation at Site NS1.

Plan Policy SP1

5.00 PARA 14 states there is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-making

The word sustainable is given in the Ministerial Foreward of the NPPF to mean:- ensuring better lives for ourselves without making lives worse fr future generations.

and opened to people to experience it, to the benefit of body and soul.

5.01 Para 15 states:- All Plans should be based upon and reflect the presumption in favour of sustainable development

Thus development on Green Belt land - as on Plan sites BA1, LG1, NS1, HT1, GA1, GA2, EL1, EL2, EL3 must, under the above definition of sustainability, make lives worse for those in the future, who would otherwise have enjoyed the Green Belt for walks on foot, by horse, for play/leisure, discovering and enjoying wildlife and for its views as are currently being enjoyed by the present generation.

Thus the Plan contravenes the NPPF both in the Foreward and in Paras 14 and 15.

Policy SP5 - Countryside and Green Belt

6.00 In Policy SP5 NHDC states :- We support the principles of the Greeen Belt and recognise the intrinsic value of the countryside.

6.01 CORE PLANNING PRNCIPLES, Para 17 states the Core 12 Principles for Plan-making and decision-making.

The 5th Principle requires the protection of Green Belts.
The 8th Principle requires the re-using of Brownfield land.

The Plan contravenes the 5th Core Principle ins ites BA1, LG1, NS1, HT1, GA1, GA2, EL1, EL2, EL3.

6.02 Para 79 of the NPPF is crucially important as it defines the Green Belt here:- The Government attaches great importance to Green Belts. The fundamental aim of Green Belt Policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

In Policy SP5 the NHDC accept Para 7 of the NPPF which determines that permanence is one of the essential characteristics of the Green Belt. Yet the Plan intends to remove land from the Green Belt, thereby destroying is permanence and contravening Para 79 and the Plan's own statement of agreement with Para 79.

6.03 Para 80 states that:

Green Belt serves five purposes:

Amongst these:

To check the unrestricted sprawl of large built-up areas.
To prevent neighbouring towns from merging into each other.
To assist in guarding the countryside from encroachment.
To preserve the setting and special character of historic towns.

Hence Para 80 gives the reasons for the establishment of the Green Belt legislation.

The Plan contravenes all four of these purposes in several proposed housing sites. For example:

6.04 The urban sprawl of Stevenage is exampled in sites GA1 and GA2 and also in NS1 which is designed to integrate (Policy SP16) with an adjoining proposed development in the Stevenage Borough (SBC) Local Plan to create a combined urban sprawl from Stevenage to the village of Graveley of 1.3 kms in depth. This is a monstrous contravention of the above four purposes of Para 80.

6.05 The third purpose of Para 80 I breached by sies GA1, GA2, NS1, BA1, LG,HT1, EL1, EL2, EL3.

6.06 The preservation of the setting and special characteristics of historic towns (the fourth purpose given in Para 80) is contravened in particular at Baldock and at Graveley where the proposed number of houses (2800 at BA1 and 900 at NS1) will have an enormous deleterious effect relative to the present number of houses in these two places.

6.07 Para 83 of the NPPF states that once established, Green Belt boundaries should only be altered in exceptional circumstances.

In Para 83 no more explicit definition is placed upon the phrase "exceptional circumstances".

6.08 In Policy SP5 the Plan quotes the judgement of Mr Justice Jay in the Calverton Parish Council v Greater Nottingham Councils (2015) EWHC 1078 case as justification for building on Green Belt land.

Mr Justice Jay stated that:- It would be illogical and circular, to conclude that the existence of an objectively assessed (housing) need could, without more, be sufficient to amount to "exceptional circumstances" within the meaning of Paragraph 83 of the NPPF".

The Plan does not provide evidence to show "exceptional circumstances" other than housing need, which is specifically rejected by Mr Justice Jay.

The following discusses the phrase "exceptional circumstances" in the event that the Local Plan is later modified to include certain circumstances purported to be acceptable within Para 83

7.00 It cannot be the case that a circumstance be considered as "exceptional" within the meaning of Para 83 or "very special" within the meaning of Paras 87 and 88 if the employment of that particular circumstance effectively destroys the fundamental purposes of the Green Belt as described in Para 80, or the essence of the Green Belt as described in Para 79. For if the purpose or the essence of the Green Belt is destroyed then Paras 83,87, and 88 themselves become meaningless.

7.01 The destruction of the essence of the Green Belt occurs when its openness is challenged by erecting buildings upon it. The destruction of the permanence of the Green Belt occurs if any part of Green Belt land is later designated as non-Green Belt land. Even relatively small incursions of the Green Belt have the effect of destroying the essence of the Green Belt when continuously repeated, as they may be.

7.02 The Hon Mr Justice Jay suggests five possibilities for exceptional circumstances:

1) The acuteness of the need
2) Constraints on the supply of available land
3) The difficulty of finding non Green Belt sites
4) The nature and extent of the Green Belt if developed
5) The extent to which the loss of Green Belt may be ameliorated.

7.03 My comment on Mr Justice Jay's ruling is that his 5 permissible exceptions destroy the intent and essence of the Green Belt as described in Para 79 and contravenes the purposes of the Green Belt as described in Para 80 and are therefore not permissible.

7.04 One should consider:

1) the acuteness of the need. Firstly, the need for housing must be determined within the restraints of Para 158. Under those circumstances the true need may not be acute, as is the case described in Paras 1.00 - 1.12 above. Need is an objective assessment which has to be considered whether it is exceptional compared to previous occasions eve though subjectively considered currently high.

It is not acuteness that matters it is exceptional acuteness.

2) No matter the constraint on land supply there always exists the possibility of building on non-Green Belt land in the form of a New Town or on Brownfield sites or on other green spaces owned by the NHDC (Barkas [2014]) Any constraint which still exists after all other avenues have been explored in its self has to be exceptional compared to previous constraints.

3) There may be difficulties but all other possibilities must first be considered. Once again the difficulties must be compared to previous difficulties in order to show exceptionality.

4) One exceptional characteristic of Green Belt (Para 79) is its permanence which thus denies the allowance of even small harms.

Thus the nature and extent of the harm is not an issue if no harm may be done.

5) A loss of Green Belt violates the essence of the NPPF as described in Para 79, so amelioration is not an issue.


8.00 Para 89 states a local planning authority should regard the construction of new buildings as inappropriate in Green Belt.

The exceptions listed are not applicable to the Local Plan. This definition of inappropriateness applies to Paras 87 and 88 and elsewhere. Thus the construction of new buildings is not allowed on the Green Belt. Thus the Plan contravenes Para 89 of the NPPF in proposing building on sites. GA, GA2, NS1, BA1, LG1, HT1, EL1, EL2 AND EL3.
.

Plan Policy SP10

8.01 Para 7 of the NPPF - a social role -states that the supply of housing is required to meet the needs of present and future generations.

Thus it is necessary to have an accurate prediction of the type and size of future generations. The inaccuracy of the housing need figures employed by the Plan is addressed under the Section Not Positively Prepared, above.

8.01 The Plan is seriously flawed in that it cannot meet the needs of a future generation as it does not employ the most accurate projection of the size and make-up of that future generation.

Thus the Plan is in contravention of the requirement of the NPPF Para 7.

Plan Policy SP13

9.00 The Ministerial Foreward of the NPPF also states that :
Our historic environment - buildings, landscapes, towns and villages - can better be cherished if their spirit of place thrives rather than withers.

The spirit of the small town of Baldock (BA1, 2800 extra houses) and that of the village of Graveley (NS1, 900 extra houses planned - a 450% increase) and Codicote (CD1, CD2, CD3,CD4, a 24% increase) for example, cannot be expected to survive undiminished if this Plan is implemented.
Thus Para 14 of the NPPF is contravened by the Plan.

10.00 Conclusion

The object of the NHDC Local Plan appears to be to maximise the number of houses built - whether on Green Belt or not - and irrespective of the requirements of the NPPF and the true needs of the current population. The requirements of the NPPF are observed more in its breach than in its observance despite several exhortations to the contrary. It is only logical to assume that the Government's New Homes Bonus - which is designed to encourage more house building- is working very effectively at NHDC.


ADDITIONAL COMMENTS

I wish to draw to your attention to the fact that I have emailed Cllr Levett, Planning Officer about a Green Belt matter which much concerned me and not received a reply at all. See below my email relating to recorded comment in Minutes of Cabinet Meeting July 20th 2016.

David

I still have not had a reply to my email of 21 September 2016 to explain how your comment on 20 July, which was a recorded comment saying that you were increasing the Green Belt.

Yu certainly aren't doing that in Graveley !!!!








I have asked for maps of GA1, GA2 and NS1 not for myself, but for other people at their request, because they could not locate the maps themselves. I was advised of the wrong location on the Local Plan information for these maps by Nigel Smith, NHDC's Principal Strategic Planning Officer.

I noted that Minutes of a Cabinet Meeting which took place in September 2016 were not made available to the public until November 2016 relating to adopting the Local Plan. This seems an excessively long time to publish Minutes. I asked the person responsible for compiling them for a copy but was never sent them.

On the subject of Brownfield sites, I emailed Planners for a map or list of Brownfield sites. The response was that NHDC does not hold such a thing. I then found out that I should have done a Freedom of Information Request to enable me to obtain this information. It is concerning that NHDC will not divulge such information willingly and I have been informed by a District Councillor that brownfield sites have been discussed at NHDC Council Meetings and rejected out of hand.

My over-riding concern is that this Local Plan has not taken account of residents' wishes at all. I went to the public meeting where the Local Plan was voted upon by Councillors, on 20 July 2016 which started at approx. 7.30 pm but did not end until after well after 12.midnight. the following day. The atmosphere, pushed hard by Cllr Levett, the Planning Official who created the Plan was of the very unpleasant type of very hard selling such as the elderly and vulnerable experience when someone intent on obtaining their bank details marches them off to the nearest cash point to take all their money out. He kept forcing Councillors, who had reservations about the Plan, and voiced them at the time to vote in favour of it. Councillors there said they "struggled" with it, and there were abstentions and some against.

I am told by a new LibDem Councillor that he was told he had to vote in favour of the Plan, by a person in the Legal Department of NHDC who was present on the panel at that meeting. Conservative Councillors also actually said that they had been forced to vote for the Local Plan or be ejected from their local party. All very unpleasant to see unfolding before your eyes.


Relevant Recent Case to NS1- November 2016 Planning Inspector P.Major Langley Burrell, Chippenham



There was another recent case where In the final balance, the secretary of state agreed with his Inspector that although the area had no special landscape character, the loss of the gap between the surrounding settlements involved physical intrusion into an area of countryside, and contributed to coalescence and loss of independent identity. See details below:Suffolk Coastal DC v Hopkins Homes Ltd and Richborough Estates Partnership LLP v Cheshire East BC,

The secretary of state has rejected a large housing scheme in Hampshire, finding the loss of an area of local green gap to outweigh the benefit of new housing in making his decision on a recovered appeal.
The proposed new housing estate of up to 225 homes plus a 60 bed care home and 40 extra care units, in outline, was acknowledged to contribute to housing supply in an area with a 4.86 year supply and to the choice of housing types meeting different needs, in accordance with NPPF policy.
Since the inquiry closed, judgment was handed down by the Court of Appeal in Suffolk Coastal DC v Hopkins Homes Ltd and Richborough Estates Partnership LLP v Cheshire East BC, which led the secretary of state to decide a local gap policy was relevant to the supply of housing, contrary to the inspector's view in the appeal. Although the policy was out of date, it was accorded significant weight in the decision because it accorded with the NPPF and the housing shortfall was only limited.
In the final balance, the secretary of state agreed with his inspector that although the area had no special landscape character, the loss of the gap between the surrounding settlements involved physical intrusion into an area of countryside, and contributed to coalescence and loss of independent identity. This was contrary to those policies of the NPPF which recognised the different roles and character of different areas, and carried significant weight against the proposal. The loss of best and most versatile agricultural land also carried moderate weight against the proposal in the decision.
Inspector: John Chase; Inquiry

Other concerns that I have about development in NS1 is the increase in traffic if development of GA1 goes ahead. It is intolerable already to encounter the queues of traffic outside my house at 7.30 am speeding towards the roundabout (Coreys Mill) and Church Lane is extremely narrow and rural. I will find any further increase unbearable and will affect my quality of life.

A major concern to me is the destruction of wildlife such as fallow deer, badgers and Pipistrelle bats who have setts in the woods such as Roundwood. [...]

It also concerns me that thousands of houses are to be built so that I will no longer be able to go for walks near to where I live. This will have an adverse effect on my wellbeing and health.

I would like to add that everyone I have met who has been doing Representations has found them very very difficult to do. In one area (GA2) even though Cllr Henry lived there only 75% of residents had heard of what was planned in their area. I know that because I called on some of these residents and leafletted these people as they were "horror stricken" when they found out only a couple of weeks ago. Why were none of them informed by NHDC ? I am surprised and amazed that Cllr Henry nor NHDC had bothered to tell them or tell them they should be making a Representation.